https://www.taxtmi.com/caselaws?id=325186 A non-resident was found to have a business connection in India under section 9(1)(i) because the foreign contracts were implemented through an Indian entity and the operations were commercially intertwined. However, no fixed place PE was established as the treaty disposal test under the India-UK DTAA was not met, while service PE and dependent agent PE were also not proved because the record did not show services performed in India by the foreign enterprise or habitual contract conclusion by the Indian entity. No further profit was attributable after arm's length transfer pricing compensation, as additional attribution would duplicate the same functions, assets and risks. Amounts for access circuits and bandwidth, to the extent not pure pass-through, were treated as royalty and taxed on a gross basis. en-us Fri, 04 Mar 2016 00:00:00 +0530 Fri, 11 Mar 2016 19:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=325186 A non-resident was found to have a business connection in India under section 9(1)(i) because the foreign contracts were implemented through an Indian entity and the operations were commercially intertwined. However, no fixed place PE was established as the treaty disposal test under the India-UK DTAA was not met, while service PE and dependent agent PE were also not proved because the record did not show services performed in India by the foreign enterprise or habitual contract conclusion by the Indian entity. No further profit was attributable after arm's length transfer pricing compensation, as additional attribution would duplicate the same functions, assets and risks. Amounts for access circuits and bandwidth, to the extent not pure pass-through, were treated as royalty and taxed on a gross basis. Case-Laws Income Tax Fri, 04 Mar 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=325186